On April 05, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Fernandez, Evelyn,
and
Miami-Dade County, Fl,
for Equitable Relief
in the District Court of Miami-Dade County.
Preview
Filing # 69736537 E-Filed 03/23/2018 02:46:53 PM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
EVELYN FERNANDEZ, GENERAL JURISDICTION DIVISION
Plaintiff, CASE NO.: 17-8126 CA 09 (Echarte)
vs.
MIAMI-DADE COUNTY,
Defendant. /
MIAMI-DADE COUNTY’S MOTION FOR EXTENSION OF
TIME TO RESPOND TO THE THIRD AMENDED COMPLAINT
Defendant, Miami-Dade County (“the County”), by and through undersigned
counsel, moves for an extension of time of seven (7) days from the due date to file a
response to Plaintiff's Third Amended Complaint and states as follows:
1 Plaintiff filed the Third Amended Complaint on March 11, 2018
Accordingly, the response is presently due on March 26, 2018.
2. Due to conflicts, defense counsel requests a seven (7) day extension of time
from March 26, 2018 to file a response to the Third Amended Complaint.
3. Defendant made multiple good faith attempts to contact Plaintiff’ s counsel,
Teri Guttman Valdes, who has yet to respond with her position on this motion.
4. The instant motion is brought in good faith and not for purposes of delay.
WHEREFORE, the Miami-Dade County respectfully requests that the Court enter
an order granting the seven (7) day extension of time up to and including April 2, 2018, to
file its response to the Third Amended Complaint.Case No.: 17-8126 CA 09
Respectfully submitted,
ABIGAIL PRICE-WILLIAMS
Miami-Dade County Attorney
Stephen P. Clark Center, Suite 2810
111 Northwest First Street
Miami, Florida 33128-1993
By: s/Ezra S. Greenberg
Ezra S. Greenberg
Assistant County Attorney
Florida Bar Number 85018
Telephone: (305) 375-5151
Fax: (305) 375-5634
Email: ezrag@miamidade.gov
dmh@miamidade.gov
Attorney for Defendant Miami-Dade County
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was
electronically filed with the Florida Court’s E-Filing Portal and was served via e-mail
generated by the Florida Courts E-Filing Portal on March 23, 2018 to:
Counsel for Plaintiff
Teri Guttman Valdes, Esq.
Teri Guttman Valdes, P.A.
1501 Venera Avenue, Suite 300
Coral Gables, FL 33146
Tel: (305) 740-9600
Fax: (305) 740-9202
E-mail: tgvaldes@aol.com
s/Ezra S. Greenber,
Assistant County Attorney
Document Filed Date
March 23, 2018
Case Filing Date
April 05, 2017
Category
Equitable Relief
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Filing # 69736537 E-Filed 03/23/2018 02:46:53 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA EVELYN FERNANDEZ, GENERAL JURISDICTION DIVISION Plaintiff, CASE NO.: 17-8126 CA 09 (Echarte) vs. MIAMI-DADE COUNTY, Defendant. / MIAMI-DADE COUNTY’S MOTION FOR EXTENSION OF TIME TO RESPOND TO THE THIRD AMENDED COMPLAINT Defendant, Miami-Dade County (“the County”), by and through undersigned counsel, moves for an extension of time of seven (7) days from the due date to file a response to Plaintiff's Third Amended Complaint and states as follows: 1 Plaintiff filed the Third Amended Complaint on March 11, 2018 Accordingly, the response is presently due on March 26, 2018. 2. Due to conflicts, defense counsel requests a seven (7) day extension of time from March 26, 2018 to file a response to the Third Amended Complaint. 3. Defendant made multiple good faith attempts to contact Plaintiff’ s counsel, Teri Guttman Valdes, who has yet to respond with her position on this motion. 4. The instant motion is brought in good faith and not for purposes of delay. WHEREFORE, the Miami-Dade County respectfully requests that the Court enter an order granting the seven (7) day extension of time up to and including April 2, 2018, to file its response to the Third Amended Complaint.Case No.: 17-8126 CA 09 Respectfully submitted, ABIGAIL PRICE-WILLIAMS Miami-Dade County Attorney Stephen P. Clark Center, Suite 2810 111 Northwest First Street Miami, Florida 33128-1993 By: s/Ezra S. Greenberg Ezra S. Greenberg Assistant County Attorney Florida Bar Number 85018 Telephone: (305) 375-5151 Fax: (305) 375-5634 Email: ezrag@miamidade.gov dmh@miamidade.gov Attorney for Defendant Miami-Dade County CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was electronically filed with the Florida Court’s E-Filing Portal and was served via e-mail generated by the Florida Courts E-Filing Portal on March 23, 2018 to: Counsel for Plaintiff Teri Guttman Valdes, Esq. Teri Guttman Valdes, P.A. 1501 Venera Avenue, Suite 300 Coral Gables, FL 33146 Tel: (305) 740-9600 Fax: (305) 740-9202 E-mail: tgvaldes@aol.com s/Ezra S. Greenber, Assistant County Attorney